MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on the parties' cross-motions for partial summary judgment under Rule 121. Unless otherwise indicated, section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner Robert K. Lowry (petitioner) was a partner in a partnership that realized taxable income from cancellation of indebtedness...
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